2022 (7) TMI 221

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....assessment year 2016-17. 2. In its appeal, the assessee has raised following grounds:- "(a) The Id CIT(Appeals) erred in facts and law in not condoning the delay in filing the appeal without appreciating that the assessee had taken recourse to rectification application u/s 154 of the Act being one of the alternative remedies provided by the statute to avoid undue litigations and that the same does not automatically exhaust the right of the assessee to avail other vested remedies viz. appeal u/s 250 of the Act. (b) The Id. CIT(Appeals) erred in facts and law in not appreciating that the assessee approached the appellate authority for grant of relief as a result of no action taken by the Id. Assessing Officer in pursuing ....

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....9.10.2018, passed under section 143(3) of the Act computed the disallowance of Rs.3,09,852, under section 14A of the Act r/w rule 8D of the Income Tax Rules, 1962 ("Rules"). 4. The learned CIT(A), vide impugned order dated 14/06/2021, dismissed the appeal filed by the assessee on the ground of delay by observing as under:- "8.4. On these contentions of the Appellant, I have noted that except for the averments made in the letter for condonation of delay, no other documentary evidence has been filed by the Appellant. There is no evidence on record to even substantiate the contention of the appellant that it actually had filed a petition u/s 154 before the AO. However, even if the submissions of the assessee in this regard is accep....